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Lottery Sector Changes – Advertising and Gambling Commission Changes

Licence Conditions and Codes of Practice (LCCP) Changes

Operators should be up to speed with the latest version of the LCCP and aware that this currently is changing twice annually. The most recent changes to the LCCP that affect lottery operators are as follows:

  • Licence condition 15.1.1
  • Licence condition 15.2.1
  • Licence condition 15.2.2
  • Licence Condition 15.3.1
  • Social Responsibility Code Provision 6.1.1
  • Personal Licence conditions

It is important that operators read these conditions and understand how they may affect their day to day business and whether any policies need to be amended to reflect these changes and ensure compliance with the same.

The changes in the LCCP concern reporting obligations and display of licensed status for remote operators. It is always strongly advised that an up to date copy of the LCCP is readily available to all of those concerned with the gambling industry and, where hard copies are not presented, employees know where to find the most recent version (online).

The Committee of Advertising Practice (CAP) and Broadcast Committee of Advertising Practice (BCAP)

CAP and BCAP have recently amended its guidance regarding the feature of children and young people in lottery advertisements. The wording of the original rules was:

17.15 Marketing communications for a lottery product may include children or young persons. No one who is, or seems to be, under 25 years old may be featured gambling or playing a significant role.

17.16 Marketing communications that exclusively feature the good causes that benefit from a lottery and include no explicit encouragement to buy a lottery product may include children or young persons in a significant role.

The amended wording of the rules is as follows:

17.15 [Marketing communications] for lotteries must not feature anyone who is, or seems to be, under 25 years old (under 25s) participating in gambling.

17.16 [marketing communications] for lotteries which include any reference to scratch cards or online instant win lottery products must not feature under 25s in a significant role. Other [marketing communications] for lotteries must not feature under 25s in a significant role unless either:

17.16.1 The under 25s are featured solely to depict the good causes supported by the lottery and there is no explicit encouragement to purchase a lottery product; or

17.16.2 The lottery primarily benefits under 25s (including in a family setting) and the under 25s featured are representative of the primary beneficiaries of the lottery.

 In addition to the changes of the wording, CAP have published guidance on the depiction of under 25s in lottery advertising and, in particular, what they deem significant role to mean. They have split the definition of significant role into “incidental” and “significant”.


  • Under 25s seen as a minority part of a larger mixed age group, where the focus is on the group as a whole, e.g. a family a dinner.
  • Under 25s in the background of a shop that focuses on older subjects.


  • Speaking parts (or written equivalents in non-broadcast advertising).
  • The sole or primary focus of a shot, or being singled out in some way.
  • Holding promotional materials, such as a sign for the cause or lottery.

The distinction between scratch cards and instant win lotteries have always been of higher risk profile because of the potential harm to players.

It is important that you are aware of these new rules and ensure that your advertisements are compliant with the new rules.

Guidance from CAP can be found of the following link:

If you have any questions in relation to this guidance, then please contact Sarah Frow or Andrew Woods on 0113 234 3055 or